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—that is, that this was a slump transaction. ’ ’ In Frankel Corpn. Ltd. v. ... Fisher or from MacCarthy & MacCarthy, a firm of solicitors, he forwarded the remaining photographs to the latter firm. ... Or kin & An. (1935), A.D. 18).) It is inappropriate to speak about ‘reducing’ a ‘thought’ or reducing a mental process. ...

The appellant was, prior to 1954, engaged in the business of building houses — some under contract for others and some on his own account for re-sale. ... Early in 1954, the appellant caused a company — Stephen Sura Ine. — to be incorporated, and from that time on, the appellant carried on for the account of the company the business that he had previously carried on for his own account, with this additional feature, that, when he — as Stephen Sura — found land that he decided should be acquired to be used in the company’s house-building business, he acquired on his own account and so held it until the company was ready to acquire it and use it, at which time he sold it to the company at its cost to him. ... Having reached that conclusion, I must conclude, as President Thorson did in the Taylor case, that the property having been acquired in the course of an operation of a business character, a profit from its disposition, at least in the circumstances under which the land was sold in this case, is a profit from a ‘‘ business’’ within the extended meaning of that word as used in the Income Tax Act. ...

This section reads: ‘‘ Where a corporation in a taxation year received a dividend... ”, while Section 6 is thus worded: “Amounts received in the year as dividends’’. ... Justice Rowlatt said (p. 595, in fine): “... receivability without receipt for the purpose of Income Tax is nothing at all. ... " 29 True this rule may be subject to exceptions, but the exceptions must be clearly expressed in the statute. ...

The computation of 1955 taxable income of the company as determined by the re-assessment is: Taxable income declared by company $ 789.76 Capital cost allowance claimed by com pany $4,570.17 Capital cost allowance as determined by the Minister 104.67 Add to income as declared 4,465.49 Taxable income as revised and as assessed $5,255.25 Benjamin Richard Steen, the president of the company, testified respecting the 1946 acquisition of the property. ... At the time of the sale the rentals being derived from the buildings were: Zenith Electric Supply — $2,000.00 per month Herbert A. Watts Limited 855.00 u “ Stephen Sales Limited 541.66 u *: Trevelyan Manufacturing Co. 225.00 ‘:‘ cs $3,621.66 The annual gross income approximated $44,000.00 and the annual net income, before administration expense, was in the vicinity of $22,000. ...

By the Minister’s notifications dated May 19, 1959, he confirmed the said assessments as having been properly made in accordance with the provisions of the Act, and added, ‘ ‘ The provisions of Section 85A of the Act are not applicable.” ... You will receive 10,000 shares of Escrow stock in Aggregates & Construction Products Ltd. ...

"‘What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts; the question to be determined being— Is the sum of gain that has been made a mere enhancement of value by realising a security, or is it a gain made in an operation of business in carrying out a scheme for profit making. ‘ ‘ The Court came to the conclusion that the sale of the property in question was a proper trading transaction. ... He said of its transactions in the raw sugar futures market: " " I think it is difficult to disassociate them from what took place in the first instance.” ...

of a corporation ‘‘as if’’ he owned certain shares in that corporation, does it follow that the person who during that period actually owned those shares is “deemed” to have had during that period “ the same position in relation to... control ’ ’ of that corporation ‘‘as if ” he did not own those shares? ... Inasmuch as subsection (dd) is an interpretation provision that may have operative effect in several different parts of the Act, it is not improper to consider first, in general terms (and without in- tendng to express any opinion concerning the precise effect of provisions relating to other problems), the background of the Act as a whole in so far as the concept of control ” of a corporation is concerned. ...

& L. Investment Co. for the sum of $453,096, being the cost thereof to T. ... & L. Investment Co. and its directors in England and Canada until 1959. ... That is to say, the revenue from the Class C ’ ’ farms was the approximate equivalent from those on the Class “A” and “B” farms on a percentage basis. ...

Berry, then President of National Light & Power Company Limited of Moose Jaw, with Mr. ... Kal- macoff and unanimously carried: " That the directors are authorized to negotiate the purchase from J. ... Nixon 5000 “ M. F. Harwood 4999 (V. L. Smith 1 And the minutes also shows the following: " "Whereas the following persons have subscribed for debentures in the amounts set forth opposite each name, be it resolved: ‘That the President and Secretary are hereby authorized to issue and deliver upon payment of the par value the following debentures in the amounts provided in this resolution: K. ...

The Massawippi Valley Railway, then: “... by these presents do demise and lease for the said period or term of nine hundred and ninety years... ... Planiol and Ripert, in their exhaustive treatise of ‘‘ Droit Civil” (1930 ed. ... Fordham, Q.C., the learned member of the Tax Appeal Board who first heard the case; I quote: ‘,.. ...